District of Columbia v. Pierce Associates, Inc.

FERREN, Associate Judge:

In this case, we originally held, in Part III of our opinion, that the District of Columbia erred in apportioning and taxing, as business income, the insurance proceeds that the taxpayer received for flood damage to its Virginia manufacturing facility. District of Columbia v. Pierce Associates, Inc., 440 A.2d 325, 330-31 (D.C.1981). On that issue alone, the District petitioned for rehearing. After consideration of the petition, the taxpayer’s answer, and the submissions of the amicus curiae (the Multistate Tax Commission), and after reargument, we conclude that the…